18 U.S.C. § 1423
Misuse of evidence of citizenship or naturalization
Whoever knowingly uses for any purpose any order, certificate, certificate of naturalization, certificate of citizenship, judgment, decree, or exemplification, unlawfully issued or made, or copies or duplicates thereof, showing any person to be naturalized or admitted to be a citizen, shall be fined under this title or imprisoned not more than five years, or both.
Notes of Decisions
Cited in 7
cases (1 in the last 5 years), 1951–2025 · leading case: United States v. Divna Maslenjak
United States v. Divna Maslenjak (2016)
“§ 1425 (a) and of knowingly using an unlawfully issued certificate of naturalization in violation of 18 U.S.C. § 1423 . On appeal, Maslenjak argues that the district court improperly instructed the jury that her false statements need not be material in order to convict Maslenjak…”
United States v. Justo Jonah Santos (2020)
“§ 1425 (a) (Count 6 Case: 18-14529 Date Filed: 01/09/2020 Page: 7 of 45 One), and one count of misusing evidence of citizenship or naturalization, in violation of 18 U.S.C. § 1423 (Count Two). Santos was tried twice.”
UNITED STATES of America, Plaintiff-Appellee, v. Heriberto BAHENA-CARDENAS, Defendant-Appellant (1995)
“The government's motion to dismiss Count 3, misuse of evidence of citizenship in violation of 18 U.S.C. § 1423 was granted. Therefore, Bahe-na-Cardenas was tried and convicted on only two counts of the original three-count indictment.”
United States v. Divna Maslenjak (2019)
“§ 1425 (a); and (2) misuse of evidence of naturalization or citizenship, in violation of 18 U.S.C. § 1423 . At trial, the district court instructed the jury that it could convict Maslenjak of procuring her naturalization contrary to law based on a false statement in the…”
United States v. Schneiderman (1951)
“§ 331 , misuse of evidence of citizenship, 18 U.S.C. §§ 1423 , 1424, 1428, willful issuance of a false crop report, 18 U.”
United States v. Orlando Chavez (2025)
“§1425 (a), and misuse of evidence of citizenship or USCA11 Case: 25-10314 Document: 33-1 Date Filed: 12/19/2025 Page: 2 of 7 2 Opinion of the Court 25-10314 naturalization, in violation of 18 U.S.C. § 1423 . On appeal, Chavez argues that the district court erred by denying his…”
United States v. Michael Roy Fraser (2019)
“§ 1425 (a), and using an unlawfully procured certificate of naturalization as proof of citizenship, see 18 U.S.C. § 1423 . At trial, the government introduced a videotaped recording of a U.”
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